Once limited to hospitals and physicians’ offices, intravenous (IV) hydration therapy, has become increasingly accessible to consumers seeking enhanced hydration, essential nutrients, or wellness benefits. This rapid expansion, driven by entrepreneurial innovation, has attracted heightened regulatory scrutiny.

On October 22, 2025, the Wisconsin Department of Safety and Professional Services (“DSPS”) issued its first formal guidance on IV hydration therapy clinics through its newly formed Interdisciplinary Advisory Committee (the “Committee”). The Committee includes representatives from multiple professional boards, including the Medical Examining Board, Board of Nursing, Pharmacy Examining Board, Controlled Substances Board, Cosmetology Examining Board and Physician Assistant Affiliated Credentialing Board. This guidance underscores regulators’ growing focus on the IV therapy industry.

Key Regulatory Interpretations

The Committee reaffirmed that IV therapy constitutes a medical treatment under Wisconsin law. Accordingly:

• IV procedures must be performed by appropriately licensed medical professionals.
• Certain license types, such as registered nurses, cannot diagnose or independently order IV therapy, as this falls outside their scope of practice.
• Businesses offering IV services must verify that all practitioners are properly licensed. Failure to do so may result in disciplinary action against the provider, the business, and any delegating physicians or advanced practice clinicians.

The guidance addresses three critical stages of IV therapy: assessment, compounding, and administration.

1. Patient Assessment
Clinics must ensure that assessments meet Wisconsin’s medical standards. A qualified practitioner must assess the patient prior to ordering treatment. The guidance notes that only physicians, physician’s assistants, or advanced practice nurse prescribers can conduct patient assessments and emphasized the importance of the practitioner having appropriate education, training and experience relevant to IV therapy. Language from earlier drafts of the guidance that discouraged telehealth was removed, but the Committee cautions that telehealth assessments may not satisfy the required standard of care. At minimum, assessments should include a physical examination and medical history conducted by the prescribing practitioner. Informed consent must contain the risks of additives to saline, the risks of IV fluids, and the risks of an IV itself. Standing orders may only be used after a valid provider-patient relationship has been established.

2. Compounding
Formulating IV solutions constitutes drug compounding and must comply with federal and state requirements, including the Food, Drug, and Cosmetic Act, United States Pharmacopeia (USP) standards, and Wisconsin Pharmacy Examining Board rules. Most IV clinics fall under USP’s “immediate use” provisions, which mandate written standard operating procedures, licensed and trained personnel, proper labeling, and aseptic handling of sterile solutions.

3. Administration
IV administration may be performed by a registered nurse or limited practice nurse, provided proper delegation and supervision occur. Clinics must maintain continuous oversight during administration and ensure documentation meets Wisconsin’s legal standards for medical and nursing practices.

Implications for IV Hydration Therapy Providers

Although the Committee’s guidance does not create new law, it reflects regulators’ interpretation of existing requirements and will influence DSPS enforcement actions. IV therapy providers should review their compliance protocols for every stage of treatment to mitigate legal and operational risks.

For additional information or to schedule a compliance check-in, please contact Katelyn Pellitteri, Adam Witkov, or your contact within the Michael Best healthcare team.